K Number
K191431
Device Name
Interlude Rolled Tampons in Plastic Applicator
Manufacturer
Date Cleared
2019-10-07

(131 days)

Product Code
Regulation Number
884.5470
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Interlude rolled tampons in plastic applicator are inserted into the vagina and used to absorb menstrual or other vaginal discharge.
Device Description
Interlude rolled tampons in plastic applicator are menstrual tampons used to absorb menstrual fluid. These tampons will be provided with 3 absorbencies - Regular, Super and Super Plus. These Tampons are rolled and made from organic cotton and polymeric overwrap in which a cotton cord is inserted. The applicator tubes are made of plant-based polyethylene and include a cylindrical barrel with finger grip and a one-piece plunger. The assembled tampon with applicator is wrapped in a printed PE wrapper.
More Information

Not Found

No
The device description and performance studies focus on the physical properties and biological safety of a menstrual tampon, with no mention of AI or ML technology.

No
The device is described as a menstrual tampon used to absorb menstrual or other vaginal discharge, which is a fluid management function rather than treating or preventing a disease.

No

This device is a menstrual tampon, used to absorb menstrual fluid. It does not diagnose any condition or disease.

No

The device description clearly outlines physical components such as tampons made of cotton, polymeric overwrap, a cotton cord, and applicator tubes made of plant-based polyethylene. It also describes performance studies related to physical characteristics and biocompatibility, not software validation.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices that are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening. They are used outside of the body (in vitro means "in glass" or "in the lab").
  • Device Function: The description clearly states that the tampons are "inserted into the vagina and used to absorb menstrual or other vaginal discharge." This is a physical function performed within the body to manage a bodily fluid. It does not involve analyzing a specimen in a lab setting to diagnose or monitor a condition.
  • Intended Use: The intended use is for absorbing menstrual or vaginal discharge, not for diagnostic purposes.
  • Performance Studies: The performance studies focus on physical properties (dimensions, absorbency, strength, integrity), biocompatibility (irritation, toxicity), and microbiology related to the tampon's interaction with the body and its environment, not on the accuracy of a diagnostic test.

Therefore, based on the provided information, this device is a medical device, but it falls under a different category than In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

Interlude rolled tampons in plastic applicator are inserted into the vagina and used to absorb menstrual or other vaginal discharge.

Product codes (comma separated list FDA assigned to the subject device)

HEB

Device Description

Interlude rolled tampons in plastic applicator are menstrual tampons used to absorb menstrual fluid. These tampons will be provided with 3 absorbencies - Regular, Super and Super Plus. These Tampons are rolled and made from organic cotton and polymeric overwrap in which a cotton cord is inserted. The applicator tubes are made of plant-based polyethylene and include a cylindrical barrel with finger grip and a one-piece plunger. The assembled tampon with applicator is wrapped in a printed PE wrapper.

  • Regular size absorbency = 6 - 9 grams
  • Super-size absorbency= 9 12 grams ●
  • . Super plus size absorbency = 12 -15 grams

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

vagina

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The following performance characteristics were assessed in accordance with the 2005 FDA guidance document "Menstrual Tampons and Pads: Information for Premarket Notification Submissions (510(k)s) - Guidance for Industry and FDA Staff".

  • Dimensions
  • Absorbency range
  • Chemical residues
  • Withdrawal cord strength
  • Fiber shedding
  • Tampon integrity

Biocompatibility studies were performed in accordance with the FDA guidance document "Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1: Evaluation and testing within a risk management process" issued in 2016 and ISO 10993 standards as follows:

  • Cytotoxicity (MEM Elution Test) per ISO 10993-5:2009
  • . Sensitization (Guinea Pig Maximization Test) per ISO 10993-10:2010 (R) 2014
  • Irritation (Vaginal Irritation Test) per ISO 10993-10:2010 (R) 2014 ●
  • Acute Systemic Toxicity per ISO 10993-11:2006 ●

These tests were performed on the subject tampons and applicators, and the results met the requirements of the ISO standards.

Microbiology Testing
Per the 2005 FDA guidance document mentioned above, microbiology testing was conducted to demonstrate that the subject devices do not:

  • Enhance the growth of Staphylococcus aureus
  • Increase the production of Toxic Shock Syndrome Toxin-1 (TSST-1)
  • Alter the growth of normal vaginal microflora

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K173225

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 884.5470 Unscented menstrual tampon.

(a)
Identification. An unscented menstrual tampon is a device that is a plug made of cellulosic or synthetic material that is inserted into the vagina and used to absorb menstrual or other vaginal discharge. This generic type of device does not include menstrual tampons treated with scent (i.e., fragrance materials) or those with added antimicrobial agents or other drugs.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

October 7, 2019

ALBAAD fem c/o Robert Staab Official Correspondent Regulatory Technical Associates 30 Neck Road Old Lyme, CT 06371

Re: K191431

Trade/Device Name: Interlude Rolled Tampons in Plastic Applicator Regulation Number: 21 CFR 884.5470 Regulation Name: Unscented Menstrual Tampon Regulatory Class: II Product Code: HEB Dated: August 30, 2019 Received: September 4, 2019

Dear Robert Staab:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

1

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

for Sharon Andrews Assistant Director DHT3B: Division of Reproductive, Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K191431

Device Name

Interlude Rolled Tampons in Plastic Applicator

Indications for Use (Describe)

Interlude rolled tampons in plastic applicator are inserted into the vagina and used to absorb menstrual or other vaginal discharge.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)

|X | Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary - K191431

1. Submitter Information

Applicant:ALBAAD fem
Contact:Shlomo Helvits
Address:1, Alon Hatavor St.
Caesarea Ind. Park 3088900
Israel
Phone:+972-4-6223860
Fax:+972-4-6277022

2. Correspondent Information

Contact:Robert. J. Staab
Regulatory Technical Associates
Address:30 Neck Road, Old Lyme, CT 06371 US
Phone:+1 860-434-5872
Fax:+1 860-434-5892
Email:rta1ali1@aol.com

3. Date Prepared: October 01, 2019

4. Device Information

Device Name:Interlude Rolled Tampons in Plastic Applicator
Common Name:Unscented Menstrual Tampon
Regulation Number:21 CFR 884.5470
Regulation Name:Tampon, Menstrual, Unscented
Regulatory Class:Class II
Product Code:HEB

5. Predicate Device Information

The predicate device is Interlude and private label Unscented 3-piece compact applicator tampon (K173225). This predicate device has not been subject to a design-related recall.

6. Device Description

Interlude rolled tampons in plastic applicator are menstrual tampons used to absorb menstrual fluid. These tampons will be provided with 3 absorbencies - Regular, Super and Super Plus. These Tampons are rolled and made from organic cotton and polymeric overwrap in which a cotton cord is inserted. The applicator tubes are made of plant-based polyethylene and include a cylindrical barrel with finger grip and a one-piece plunger. The assembled tampon with applicator is wrapped in a printed PE wrapper.

  • Regular size absorbency = 6 - 9 grams
  • Super-size absorbency= 9 12 grams ●
  • . Super plus size absorbency = 12 -15 grams

4

7. Indications for Use

Interlude rolled tampons in plastic applicator are inserted into the vagina and used to absorb menstrual or other vaginal discharge.

Subject Device (K191431)Predicate Device (K173225)
Product NameInterlude Rolled Tampon in
Plastic ApplicatorInterlude and private label
Unscented 3-piece
compact applicator tampon
Classification
Regulation884.5470884.5470
Product CodeHEBHEB
Intended UseInterlude rolled
tampons in plastic
applicator are inserted
into the vagina and
used to absorb
menstrual or other
vaginal discharge.Interlude and other
private label unscented
3-piece compact
applicator tampons are
inserted into the vagina
and used to absorb
menstrual or other
vaginal discharge.
Sterile?NoNo
DesignCompact style
applicator with
cylindrical barrel with
finger grip and one-
piece plunger. Digital
tampon with round tip
and straight grooves.Compact style
applicator with
cylindrical barrel with
finger grip and two-
piece plunger. Digital
tampon with round tip
and straight grooves.
Syngyna Absorbency
(gram)Regular 6.0 - 9.0
Super 9.0 - 12.0
Super plus 12.0 - 15.0Regular 6.0 - 9.0
Super 9.0 - 12.0
NA
Pledget Length (mm)46±246+2
Pledget Diameter
(mm)11±1, 14±1, 16±114±1, 16±1
Overwrap
compositionPE/PESPE/PES
Pledget compositionOrganic cottonViscose rayon
Withdrawal cordOrganic cottonPolyester cotton
Cord length110-140 mm110-130 mm
ApplicatorLDPELDPE/HDPE barrel; PP pushers
Primary packagingPolypropylenePolypropylene

8. Comparison of Intended Use and Technological Characteristics with the Predicate Device

5

The subject and predicate devices have intended use - to absorb menstrual or other discharge in the vagina. They have the same design and comparable dimensions and absorbencies. The differences in technological characteristics do not raise different questions of safety and effectiveness.

9. Summary of Non-Clinical Performance Testing

Performance testing

The following performance characteristics were assessed in accordance with the 2005 FDA guidance document "Menstrual Tampons and Pads: Information for Premarket Notification Submissions (510(k)s) - Guidance for Industry and FDA Staff".

  • Dimensions ●
  • Absorbency range
  • Chemical residues
  • Withdrawal cord strength
  • Fiber shedding
  • Tampon integrity

Biocompatibility Testing

Biocompatibility studies were performed in accordance with the FDA guidance document "Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1: Evaluation and testing within a risk management process" issued in 2016 and ISO 10993 standards as follows:

  • Cytotoxicity (MEM Elution Test) per ISO 10993-5:2009
  • . Sensitization (Guinea Pig Maximization Test) per ISO 10993-10:2010 (R) 2014
  • Irritation (Vaginal Irritation Test) per ISO 10993-10:2010 (R) 2014 ●
  • Acute Systemic Toxicity per ISO 10993-11:2006 ●

These tests were performed on the subject tampons and applicators, and the results met the requirements of the ISO standards.

Microbiology Testing

Per the 2005 FDA guidance document mentioned above, microbiology testing was conducted to demonstrate that the subject devices do not:

  • Enhance the growth of Staphylococcus aureus
  • Increase the production of Toxic Shock Syndrome Toxin-1 (TSST-1)
  • Alter the growth of normal vaginal microflora

10. Conclusions

The subject and predicate devices have the same intended use. Although there are differences in technological characteristics between the subject and predicate devices, these differences do not raise different questions of safety or effectiveness. The performance data demonstrate that the subject devices are substantially equivalent to the predicate devices.